Our computerized control system collects, calculates, and historizes data for blends and product movements. The data can include volumes, analyzer results, manually entered lab results, etc. Data is historized by writing a file to the equivalent of a personal computer hard disk. The data collected in the files will be used for reformulated fuels documentation. The file is protected such that only a person with a physical engineering key can unprotect the file. Is this acceptable data control to the EPA?
Data control and recording systems should be proposed in the exemption request as part of an overall quality control, record keeping and review plan. All data that is generated for the batch that is intended to form a basis for the RFG certification, must be recorded and retained in a secure manner so that the auditor will be able to review accurate data for the yearly in-line blending audits.
We believe the refiner should provide reasonable security for all the data that is generated so as to retain uncompromised files and to restrict unnecessary and unauthorized access to those files. Limiting the number of persons who have access to the files is as important as who has access. (7/1/94)
This question and answer was posted at List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (pdf)